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FDIC Federal Register Citations
First Sterling Financial, Inc
From: morris hershman [mailto:mhershman@firststerling.com]
Sent: Wednesday, October 20, 2004 1:08 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
The proposed changes to the regulations regarding community reinvestment
audits of institutions with assets in excess of $250 million will be quite
detrimental to the low income housing tax credit program, which is a major
stimulus to the economy of the United States, and of great social benefit to
lower income households. Compliance with community reinvestment requirements
is a material motivation for financial institutions to make investments in
low income housing tax credit investments in areas that would otherwise have
great difficulty in obtaining such investments, despite demonstrated need
for such housing.
Morris P. Hershman
General Counsel
First Sterling Financial, Inc.
1155 Northern Boulevard, Suite 250
Manhasset, NY 11030
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